Aaron Maguregui is the catalyst driving success for early-stage health tech startups, Fortune 500 health care organizations, digital health technology companies, health care AI innovators, and general counsels seeking expert legal guidance. As a leading digital health attorney and health care AI lawyer, Aaron specializes in health technology and patient engagement strategy, AI-driven innovation, e鈥慶ommerce and technology platform negotiations and transitions, and comprehensive privacy and data governance strategy. He was recently selected to serve as Chair of the Artificial Intelligence Committee for the American Telemedicine Association, reflecting his national leadership in the intersection of AI and virtual care. With more than a decade of experience, he helps digital health CEOs, health care attorneys, retail pharmacies, health and hospital systems, pharmaceutical companies, and health care payors turn complex AI governance, HIPAA, TCPA, CMIA, CCPA, CPRA, state privacy, and telehealth regulations into strategic competitive advantages. By designing airtight HIPAA compliance programs, guiding secure e鈥慶ommerce platform migrations, implementing robust cybersecurity protocols, and negotiating seamless EHR and telehealth data sharing agreements, Aaron enables clients to accelerate product launches, build patient trust, and unlock new revenue opportunities.
- Enterprise AI Transactions: Aaron structures and negotiates enterprise-wide AI licensing and services agreements for digital health companies and healthcare organizations, enabling deployment of foundational and agentic AI tools across clinical, operational, and product teams. He advises on platform access rights, integration workflows, intellectual property protections, and data use restrictions while embedding privacy safeguards and governance controls to support responsible and scalable AI adoption.
- Accelerated Compliance & Privacy: Aaron empowers clients to launch HIPAA and TCPA compliant outreach campaigns, telehealth vendor agreements, and EHR contracts with minimal delays 鈥 minimizing audit risk and maximizing patient engagement.
- EHR and Data Integration & Strategy: Aaron has led and negotiated large scale EHR implementation and integration contracts for primary care organizations, retail pharmacies, and health systems 鈥 ensuring interoperability, cybersecurity safeguards, and HIPAA compliance while accelerating go鈥憀ive timelines.
- Telemedicine e鈥慍ommerce Launch: Aaron directs direct鈥憈o鈥慶onsumer telehealth providers through e-Commerce platform transitions, embedding secure billing workflows, HIPAA鈥慶ompliant user experiences, and robust data governance to drive patient acquisition.
- AI Governance for Expansion: From health care AI startups to medical device manufacturers, Aaron develops AI governance frameworks and drafts HIPAA, GDPR, and CCPA鈥慶ompliant data鈥憉se agreements 鈥 enabling international scalability and fostering regulatory confidence.
- Health Care Contracts & Supply Chain: As a seasoned health care contracts lawyer, Aaron structures master supply chain agreements and vendor contracts for digital health platform companies, retail pharmacies, and health IT vendors 鈥 optimizing procurement, mitigating data and privacy risks, and embedding data security requirements.
- Telehealth Platform Negotiations: He leads negotiations for nationwide telehealth platform agreements, integrating virtual care into clinical workflows and ensuring telehealth regulatory compliance reducing time to market for virtual care services.
- User鈥慍entered Digital Experiences: Aaron advises on the design of compliant, optimized user workflows and privacy controls for mobile health apps and telehealth websites. His expertise in FTC compliance, patient authentication protocols, and mobile app data security ensures regulatory adherence and superior patient experiences.
- Practical and Results Focused Approach: Aaron combines his in-house legal experience at a Fortune 100 managed care organization with his global law firm practice experience to provide practical legal guidance on platform deployments, AI compliance, and multi鈥憇tate telehealth rollouts. He stays current on regulatory developments to help clients navigate challenges and implement solutions effectively.
Aaron鈥檚 blog and speaking engagements offer practical guidance on developing and implementing HIPAA compliance programs, navigating telehealth regulations, and leveraging AI鈥慸riven legal strategies for digital health platform implementations. Read his latest articles for step鈥慴y鈥憇tep advice on data governance frameworks, telehealth integrations, and cybersecurity protocols. For assistance with EHR and technology platform implementations, telehealth vendor contracts, health care AI governance, or HIPAA鈥慶ompliant mobile app design, contact Aaron to discuss how he can translate legal requirements into actionable, growth鈥慺ocused solutions.
Representative Experience
- Enterprise Licensing for Foundational AI Model: Negotiated an enterprise-wide technology agreement with a leading large language model provider to support internal deployment of generative AI tools across product, engineering, and operational teams. The transaction included broad licensing rights, model customization terms, integration support, and usage boundaries. The agreement also addressed data handling safeguards, internal use restrictions, and privacy compliance measures to support deployment across regulated environments.
- Agentic AI Services and Integration Agreement: Structured a multi-year enterprise agreement with an agentic AI vendor delivering autonomous workflow capabilities for intake, patient support, and administrative operations. The engagement covered platform access, API integrations, intellectual property terms, and service level commitments. Privacy-related provisions included controls around system inputs and outputs, security standards for user data, and limitations on downstream use of customer data to mitigate regulatory and reputational risks.
- EHR Agreement: Negotiated and structured a multi鈥憏ear EHR agreement for a national care delivery primary care organization, ensuring interoperability standards, cybersecurity safeguards, and HIPAA compliance across all clinic locations.
- Platform Transition: Guided a direct鈥憈o鈥慶onsumer telehealth company through the negotiation and transition to an e鈥慶ommerce subscription platform for telemedicine services, embedding secure billing workflows, HIPAA鈥慶ompliant UX, and robust data governance measures.
- Retail Eyewear & Vision Services: Represented an international online retail eyewear company in the negotiation, launch, and ongoing compliance efforts of its virtual, technology-enabled vision services offering.
- AI Governance: Advised a digital health startup on an AI governance framework and drafted GDPR鈥 and CCPA鈥慶ompliant data鈥憇haring agreements for international expansion of a health care AI analytics platform.
- GPO Contracting: Represented a global health care group purchasing organization, responsible for over 30 national health care entities, in re鈥慶ontracting efforts with its primary data analytics vendor, negotiating a primary data use licensing agreement, governance agreement, and master vendor services agreement to enhance data accessibility and compliance.
- Telehealth Platform: Led the negotiation of a country鈥憌ide telehealth platform agreement for a major health network, integrating virtual care services into clinical workflows and ensuring telehealth regulatory compliance.
- UX Design: Designed and reviewed user journey workflows for a mobile mental health app, ensuring HIPAA privacy, secure authentication, and FTC鈥慶ompliant data collection practices.
- Supply Chain Agreement: Structured a master supply chain agreement for a national pharmaceutical distributor, optimizing procurement processes and mitigating regulatory risk under CMIA and federal privacy laws.
- Data Governance: Developed a data governance roadmap for a health care AI company, aligning algorithmic data usage policies with HIPAA, state AI regulatory requirements, and cloud data security best practices.
- DTC Telehealth UX: Represented a large direct鈥憈o鈥慶onsumer telehealth company in designing and developing user experience workflows, ensuring compliance with FTC regulations and enhancing patient acquisition and marketing effectiveness.
- Retail Pharmacy EHR: Negotiated on behalf of a large retail pharmacy a complex EHR agreement, integrating specialty pharmacy systems with enterprise EHR platforms, ensuring HIPAA compliance, interoperability, and optimized medication dispensing workflows.
- Platform Licensing: Represented a large retail pharmacy chain in negotiating a telehealth platform licensing agreement with a nationwide telehealth platform provider, ensuring privacy鈥慴y鈥慸esign, cybersecurity safeguards, and PHI protection.
- White Label Partnership: Represented a virtual care platform in negotiating with a pharmaceutical company to establish a white鈥憀abeled direct鈥憈o鈥慶onsumer telehealth offering, aligning branding, compliance, and operational workflows to streamline launch and patient engagement.
“Foley is the premier firm for telehealth counsel.”
“A market leader in telemedicine issues.” “This is the Dream Team.”
– Chambers USA: America’s Leading Business Lawyers (2020 – 2021)
Presentations and Publications
- Co-author, “AI-Powered Text Messaging by Digital Health Companies: Supreme Court Raises the Stakes,”聽Health Care Law Today聽(July 2, 2025)
- Co-author, “AI Contracts in Health Care: Avoiding the Data Dumpster Fire,”聽Health Care Law Today聽(June 25, 2025)
- Co-author, “HIPAA Risk Analyses for Digital Health: Navigating AI, M&A and Vendor Diligence,”聽Health Care Law Today聽(June 18, 2025)
- Co-author, “HIPAA Compliance Risks with AI Scribes in Health Care: What Digital Health Leaders Need to Know,”聽Health Care Law Today聽(June 9, 2025)
- Co-author, 鈥淭he Intersection of AI, Digital Health, and the TCPA: What You Need to Know,鈥 Health Care Law Today (May 28, 2025)
- Co-author, 鈥淐ybersecurity in Digital Health: Why HIPAA Compliance Alone Is Not Enough for M&A Success,鈥 Health Care Law Today (May 20, 2025)
- Co-author, 鈥5 Key Contracting Considerations for Digital Health Companies Working with AI Vendors,鈥 Health Care Law Today (May 15, 2025)
- Co-author, 鈥淗IPAA Compliance for AI in Digital Health: What Privacy Officers Need to Know,鈥 Health Care Law Today (May 8, 2025)
- 鈥淗ow updated third-party tech guidance affects compliance efforts.鈥 TechTarget (Mary 2, 2025) (quoted)
- Co-author, 鈥淣ew York鈥檚 Proposed Health Information Privacy Act Takes Aim at Digital Health Companies,鈥 Health Care Law Today (January 23, 2025)
- 鈥淗ealth Supply-Chain Hacks Targeted by HHS Cybersecurity Rule,鈥 Bloomberg Law (January 13, 2025) (quoted)
- Co-author, 鈥淗HS Proposes Changes to Strengthen HIPAA Security Rule,鈥 Health Care Law Today (January 6, 2025)
- Co-author, 鈥淗IPAA Reproductive Health Care Amendments: Compliance in an Uncertain Enforcement Landscape,鈥 Health Care Law Today (December 19, 2024)
- Co-author, 鈥淥CR Says HIPAA Audits Will Resume: OIG Makes Recommendations for Enhancement,鈥 Health Care Law Today (December 9, 2024)
- Co-author, 鈥淎rtificial Intelligence in Health Care: Key Considerations for Oncology,鈥 Health Care Law Today (September 25, 2024)
- Speaker, 鈥淒esigning Effective Patient Engagement Strategies for RPM Adoption and Adherence,鈥 2024 Remote Patient Monitoring Summit (September 23, 2024)
- Co-author, 鈥淲hat Goes Around Comes Around: The Resurgence of Data Breach Class Actions,鈥 Innovative Technology Insights (July 22, 2024)
- Co-author, 鈥淗IPAA: Amendments to Protect Reproductive Health Care Information Can Now be Implemented with OCR鈥檚 Final Rule,鈥 Health Care Law Today (July 2, 2024)
- Speaker, 鈥淭eamwork, Collaboration, and Intellectual Property: Common Pitfalls and Myths,鈥 ATA Nexus 2024 (May 6, 2024)
- 鈥淗ow updated third-party tech guidance affects compliance efforts,鈥 HealthITSecurity (May 2, 2024) (quoted)
- 鈥淯pdate to HHS鈥 controversial web tracker guidance offers little practical relief, legal experts say,鈥 Fierce Healthcare (March 21, 2024) (quoted)
- Co-author, 鈥淗HS Updates Pixels and Trackers Guidance for HIPAA Regulated Entities,鈥 Health Care Law Today (March 19, 2024)
- Co-author, 鈥淗IPAA and Part 2 Harmonized: What Health Care Organizations Need to Know,鈥 Health Care Law Today (February 12, 2024)
- Speaker, 鈥淐linical Implications of AI,鈥 Blue Cirrus Consulting (January 17, 2024)
- Co-author, 鈥淎I in Health Care: Powering Patient Outcomes,鈥 Innovative Technology Insights (December 11, 2023)
- Speaker, 鈥淥nline Tracking Technologies: Implications under HIPAA and Beyond,鈥 Business Research Intelligence Network鈥檚 Telehealth & Digital Healthcare Management Summit (January 22, 2024)
- Co-author, 鈥淭elehealth Providers: HHS Issues HIPAA Best Practices,鈥 Health Care Law Today (November 17, 2023)
- Speaker, 鈥淯nlocking Strategies for Telehealth Privacy,鈥 ATA EDGE2023 Policy Conference (December 13, 2023)
- Speaker, 鈥淥nline Tracking Technologies: Implications under HIPAA and Beyond,鈥 2023 North Country Leadership Summit (September 28, 2023)
- Speaker, 鈥淗ealth Law Privacy/Security Update,鈥 Association of Corporate Counsel (September 19, 2023)
- Speaker, 鈥淥nline Tracking Technologies: Implications under HIPAA and Beyond,鈥 9th Annual Northeast Regional Telehealth Conference (September 18, 2023)
- Co-author, 鈥淜ey Contractual Considerations for Health AI and Hospital Collaborations,鈥 Health Care Law Today (September 14, 2023)
- Speaker, 鈥淎I & Machine Learning in Health Care,鈥 Blue Cirrus Consulting (June 21, 2023)
- Speaker, 鈥淭elehealth Law & Policy Panel,鈥 2023 California Telehealth Summit (June 14, 2023)
- Co-author, 鈥淔lorida鈥檚 New Prohibition on Offshoring Patient Information,鈥 Health Care Law Today (May 22, 2023)
- Co-author, 鈥2023 Telemedicine & Digital Health Trends,鈥 Foley Forward: Trends 2023 (March 29, 2023)
- 鈥淔TC鈥檚 鈥楥lick to Cancel鈥 Proposal Escalates Legal Peril for Sellers,鈥 Corporate Counsel (March 23, 2023) (quoted)
- Speaker, 鈥淒igital Health Law: 2023,鈥 Health Tech Nerds (January 19, 2023)
- Speaker, 鈥淐racking Down on Security Risks,鈥 ATA EDGE Policy Conference (December 7, 2022)
- Co-author, 鈥淗HS Proposes to Align Federal Substance Use Disorder Law with HIPAA,鈥 Innovative Technology Insights (November 30, 2022)
- Speaker, 鈥淭he Legal Landscape of Telemedicine,鈥 2022 Florida Telehealth Forum 鈥 Telehealth in a Post-COVID World (September 23, 2022)
- Co-author, 鈥淗IPAA & Telehealth: FAQs from HHS Guidance on Audio-Only Telehealth,鈥 Foley Blogs (June 16, 2022)
- 鈥淩egulatory risk in the business of telehealth,鈥 Healthcare Finance News (May 2, 2022) (quoted)
- Speaker, 鈥淭he Business of Telehealth: Legal Issues Around Telehealth,鈥 ATA2022 Annual Conference & Expo (May 1, 2022)
- Author, 鈥淭he Costs and Rewards of Patient Data in the New Era of Telemedicine,鈥 Entrepreneur (April 12, 2022)
- Co-author, 鈥淔our Key Takeaways for Digital Health Companies from the FTC鈥檚 Recent COPPA Settlement,鈥 Foley Blogs (January 9, 2022)
- Co-author, 鈥淒igital Health Apps Must Allow Users to Delete Accounts, Per New Apple App Store Rules,鈥 Foley Blogs (October 10, 2021)
- Co-author, 鈥淭op 5 FAQs on the FTC鈥檚 Warning to Health Apps to Report Breaches of Health Data,鈥 Health Care Law Today (September 20, 2021)
- Co-author, 鈥淔ive To-Do鈥檚 for Telemed Companies Before the Public Health Emergency Ends,鈥 Bloomberg Law (May 26, 2021)
- 鈥淪upreme Court Ruling May Help Providers With mHealth Messaging Strategies,鈥 mHealth Intelligence (April 12, 2021) (quoted)
- Co-author, 鈥淭elemedicine, Texting, and TCPA: Telephone Consumer Protection Act Update,鈥 Foley Blogs (April 6, 2021)
- Co-author, 鈥淔AQs on Telemedicine and HIPAA During the Public Health Emergency,鈥 Foley Blogs (March 29, 2021)
- Co-author, 鈥淭elemedicine and Texting: Telephone Consumer Protection Act,鈥 Health Care Law Today (March 8, 2021)
- Co-author, 鈥淭elehealth Equity Coalition Seeks to Improve Telehealth Equity for All,鈥 Foley Blogs (February 22, 2021)
- Co-author, 鈥淎ppeals Court Vacates HIPAA Penalty Imposed Against M.D. Anderson,鈥 Foley Blogs (January 29, 2021)
- Co-author, 鈥淥CR Relaxes Enforcement on Providers Using Scheduling Apps for COVID-19 Vaccinations,鈥 Health Care Law Today (January 26, 2021)
- Co-author, 鈥淜ey Findings & Takeaways from OCR HIPAA Audit Findings,鈥 Foley Blogs (January 15, 2021)
- Co-author, 鈥淭op 5 Telehealth Law Predictions for 2021,鈥 Foley Blogs (January 12, 2021)
- Co-author, 鈥淧roposed Modifications to HIPAA Expands Individual Access Rights and Encourages Further Sharing of PHI for Care Coordination,鈥 Foley Blogs (December 14, 2020)
- Co-author, 鈥淩emote Patient Monitoring Platforms Get New Cybersecurity and Privacy Guidelines,鈥 Health Care Law Today (December 9, 2020)
- Co-author, 鈥淓uropean Commission Publishes Draft Standard Contractual Clauses,鈥 Innovative Technology Insights (December 7, 2020)
- Co-author, 鈥淎pple Requiring App Developers to Disclose Privacy Details in App Store,鈥 Foley Blogs (December 4, 2020)
- Co-author, 鈥淓uropean Data Protection Board Issues Recommendations for Exports of Personal Data From the European Economic Area,鈥 Innovative Technology Insights (December 1, 2020)
Affiliations
- Member of the International Association of Privacy Professionals
- Member of the American Health Lawyers Association
- Member of the Health Law Section of the Florida Bar
- Chaired the American Telemedicine Association鈥檚 (ATA) Data Work Group in developing its Artificial Intelligence Principles (2023)
- Co-chaired ATA’s Health Data Work Group鈥檚 Privacy Committee
Community Involvement
- Member of the board of directors for the Jason Ackerman Foundation/Because of Jason
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American Telemedicine Association Nexus 2026
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Foley again proudly continues its longstanding sponsorship of the American Telemedicine Association and ATA Nexus. ATA Nexus 2026 unites leaders from across the digital health ecosystem to explore the future of care delivery while offering deep industry insights, with the theme of Flip The Switch: Igniting Scaled Digital Health.
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